Gatlin v. St. Louis / AWS Rekognition false arrest suit (2026)

U.S. federal court — CHRISTOPHER GATLIN's civil action arising from his wrongful arrest and 17-month pretrial detention in St. Louis, Missouri. FACTUAL SEQUENCE: police investigating a DECEMBER 2020 assault on a MetroLink security guard submitted a POOR-QUALITY IMAGE OF A MASKED SUSPECT to the ST. LOUIS MUGSHOT RECOGNITION TECHNOLOGY system; the system returned GATLIN AS A POSSIBLE MATCH; he had been under NO PRIOR SUSPICION. The match caused police to include his photograph in a lineup, in which suggestive procedures influenced the victim's identification. ARREST: August 14, 2021. DETENTION: 17 months, unable to post a $75,000 bond. DISMISSAL: criminal charges dismissed MARCH 2024 after BODY CAMERA FOOTAGE revealed improper lineup procedures. THE TWO FACTS THAT MAKE THIS CASE MATTER: (1) OCTOBER 2025 \u2014 a U.S. Magistrate Judge DENIED MOTIONS TO DISMISS MOST CLAIMS, so the action survived the stage at which facial recognition wrongful-arrest suits are commonly disposed of; (2) AUGUST 2026 \u2014 an AMENDED COMPLAINT ADDED AMAZON WEB SERVICES AS A DEFENDANT. VENDOR LIABILITY IS THE NOVEL QUESTION: the wrongful-arrest cases that have shaped this area were brought against police departments and municipalities, on theories of investigative negligence and suggestive identification procedure. Naming the technology provider asks whether a vendor bears responsibility for the matches its system returns \u2014 particularly on an input its own documentation would characterise as unsuitable, a poor-quality image of a MASKED face. A masked subject is the clearest possible case of an input outside a facial recognition system's reliable operating envelope, and the system returned a name anyway. WHY THE 'NO PRIOR SUSPICION' FACT IS DECISIVE: where facial recognition merely corroborates an existing investigative lead, its contribution to the outcome is arguable; here it GENERATED the lead, so the entire chain of detention traces to the match. RELATED INDEXED MATTERS: ACLU v. Clearview AI and In re Clearview AI Class Settlement concern a different vendor and different theories. STATUS: no merits ruling; strength `unknown`.